Ezel / IRS Rulings / 201014055

CCA 201014055: IRS discusses whether an SFR is required before an FPAA

Number
201014055
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Return Prepared by IRS Personnel
Topics
Procedure, penalties, and administration
Code sections
§ 6020
Ruling dated
March 3, 2010
Publicly released
April 9, 2010
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2010, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2010
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel advice states that an IRS substitute for return is not necessary before the IRS issues an FPAA, based on confirmation from the section 6020(b) branch. The message concerns a substitute return and designation of a tax matters partner.

Ruling snapshot

  • Question: Must the IRS prepare a substitute for return before issuing an FPAA?
  • Outcome: Advice given
  • Key authorities: IRC § 6020(b)

Full text (IRS public release)

ID: CCA_2010030313205737 Number: 201014055
Release Date: 4/9/2010
Office: ----------
UILC: 6020.02-00

From: -------------------
Sent: Wednesday, March 03, 2010 1:20:59 PM
To: --------------------
Cc: ---------------------------------------------------------------------------------------------------------------------------

--------------------------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------
Subject: Substitute for Return - Designation of TMP ----------

I just confirmed with our section 6020(b) branch that it is not necessary to generate
a SFR before issuing an FPAA

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